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S-54
Reg. U-24

JNTERPRETATION OF LAW _OR REGULATION
(Copies to be sent to all Federal Reserve banks)
December 18, 1937.
Mr. _______ , First Vice President,
Federal Reserve Banl: of -------'
Dear Mr.
Reference U· made to your letter of November 19 regarding
the question whC:Jthcr a loan is subject to Regulatirm U if th.e loan
was made to purchase a stoc~{ and tho stock was regist~)red on a na-tional securities exchange at the time thv loan was made but has
since become unregistered.

As you point out in your letter, the ruling contained in
tho Board's lt:Jtter (S-31, R...;:g. U-20) of Snptcmber 2, 1937 and pub-lished at page '395 of th3 October, 1937 Federal Reserve Bulletin
doal t with the converse situation in which a stock h·J.d become regir.tered after trw loan was ronde. That ruling st~::tted thut the ques-tion of whethor or not tne lo&n there in question wu.s mude for the
purpose of purchasing vr carrying a stock "reg.i.~>tered on o. national
securities exchange 11 s!10uld oe determined on tne be. sis of the present stutus of the stock~
The Board. ~.g:rees with your view cc,ho..t, at least under the
existing regulat:.on, the qucJtion now presented should atso be· detGrminoCi. on the basis of the prusent status of the stock and that,
accordingly, in the circumstances described, the loan would not be
subject to the regulo.tion.




Ver;;r truly yours,
(Signed)

L. P. Be thew.

L. P. Bethea,
Assisk~nt

SecrGto..ry.

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